On June 25, 2019 a
Answer
was filed
involving a dispute between
Kleo Kammas,
Pantelis Kammas,
and
Aii Acquisition Corporation, Llc, Individually And As Successor-In-Interest To Athlone Industries, Inc. And Holland Furnace Company,
American International Industries, Inc.,
A.O. Smith Water Products,
Armstrong International, Inc.,
Atwood & Morrill Co., Inc. D B A Weir Valves & Controls Usa Inc.,
Aurora Pump Company,
Burnham Corporation,
Carrier Corporation,
Cbs Corporation, A Delaware Corporation, F K A Viacom Inc, Successor By Merger To Cbs Corporation, A Pennsylvania Corporation, F K A Westinghouse Electric Corporation,
Certain-Teed Corporation,
Cleaver-Brooks Company F K A Aqua-Chem, Inc.,
Columbia Boiler Company Of Pottstown,
Compudyne Corporation, Individually And As Successor To York-Shipley,
Crane Co.,
Crown Boiler Co.,
Ecr International, Inc., Individually And As Successor To Dunkirk, Dunkirk Boilers And Utica Boilers,
Flowserve Us, Inc., Solely As Successor To Rockwell Manufacturing Company, Edward Valves, Inc., Nordstrom Valves, Inc. And Edward Vogt Valve Company,
Foster Wheeler, Llc,
General Electric Company,
Goulds Pumps, Inc.,
Grinnell Corporation,
H.B. Smith Co., Inc.,
H.C. Oswald Supply Co., Inc.,
Honeywell International, Inc., Individually And F K A Alliedsignal, Inc., And As Successor-In-Interest To The Bendix Corp.,
International Comfort Products Llc, Individually And As Successor To Heil Heating And Cooling,
I.T.T. Industries, Inc., Individually And As Successor To Bell & Gossett,
Jenkins Bros.,
J.H. France Refractories Company, Individually And As Successor To Greenpoint Firebrick,
Kohler Co.,
Lennox Industries, Inc., Individually And As Successor To Lennox Furnace Company And Ducane,
Metropolitan Life Insurance Co.,
Nash Engineering Company,
New Yorker Boiler Company, Inc.,
N & S Supply Of Fishkill, Inc.,
Pecora Corporation, Individually And As Successor To Pecora Corporation, New Pecora Corporation, And New Pecora Corporation, Inc.,
Peerless Industries, Inc.,
Pennco Inc.,
Rheem Manufacturing Company, Inc.,
Riley Power, Inc. F K A Babcock Borsig Power, Inc. And F K A Riley-Stoker Corporation D B A Db Riley, Inc.,
Rockwell Automation, Inc., Individually And As Successor To Allen Bradley, Timken Heating Business And S. Co., Inc. F K A Scaife Company, As Successor In Interest To Rockwell Spring & Axle Company’S Timken Silent Automatic Division,
Sid Harvey Industries, Inc.,
Sid Harvey Supply, Inc.,
Spence Engineering Company, Inc.,
Spencer Heater, A Lycoming Division Of Avco Corporation,
Taco, Inc.,
Texaco, Inc.,
Union Carbide Corporation,
Warren Pumps Llc, Individually And As Successor To The Quimby Pump Company,
Weil Mclain, A Division Of Marley-Wylain Company,
William Powell Company,
York International Corporation, Individually And As Successor To Frick Company,
for Torts - Asbestos
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 08/05/2019 11:07 AM INDEX NO. 190153/2019
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 08/05/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
X
PANTELIS KAMMAS and KLEO KAMMAS, Index No.: 190153/2019
Plaintiffs,
- against - VERIFIED ANSWER
A.O. SMITH WATER PRODUCTS, et al.,
Defendants,
___ X
Defendant, ARMSTRONG INTERNATIONAL, INC., by its attorneys McGivney, Kluger
& Cook, P.C. answering the Plaintiff's Verified Complaint upon information and belief, alleges as
follows:
THE PARTIES
1. Defendant, ARMSTRONG INTERNATIONAL, INC. denies any knowledge or
"1"
infonnation sufficient to form a belief as to the truth of the allegations in Paragraph of the
Plaintiff's Verified Complaint.
2. Defendant, ARMSTRONG INTERNATIONAL, INC. denies any knowledge or
"2"
information sufficient to form a belief as the truth of the allegations of Paragraph and leaves
Plaintiff to their proofs.
3. Defendant, ARMSTRONG INTERNATIONAL, INC. does not answer the
"3"
allegations of Paragraph of the Plaintiff's Verified Complaint as same do not apply to this
Defendant.
4. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"4"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
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"4"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains
to the remaining defendants in the Verified Complaint.
5. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"5"
allegation contained in Paragraph of Plaintiff s Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"5"
each and every allegation contained in Paragraph of Plaintiff s Verified Coniplaint as it pertains
to the remaining defendants in the Verified Complaint.
6. Defendant, ARMSTRONG INTERNATIONAL, INC. does not answer the
"6" "8"
allegations of Paragraphs through as it contains no allegations against the answering
Defendant.
7. Defendant, ARMSTRONG INTERNATIONAL, INC. denies the allegations
"9"
contained in Paragraph of Plaintiff s Verified Complaint, insofar as they pertain to this
Defendant and denies any knowledge or information sufficient to form a belief as to the truth of each
"9"
and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the
remaining defendants in the Verified Complaint.
8. Defendant, ARMSTRONG INTERNATIONAL, INC. does not answer the
"10" "55"
allegations of Paragraphs through as it contains no allegations against the answering
Defendant.
9. Defendant, ARMSTRONG INTERNATIONAL, INC. denies the allegations
"56" "64"
contained in Paragraphs through of Plaintiff s Verified Complaint, insofar as they pertain
to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth
"56" "64"
of each and every allegation contained in Paragraphs through of Plaintiff's Verified
Complaint as it pertains to the remaining defendants in the Verified Complaint.
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AS AND FOR AN ANSWER TO THE FIRST CAUSE OF ACTION
10. Defendant, ARMSTRONG INTERNATIONAL, INC. herein repeats, reiterates and
"1" "64"
re-alleges each and every answer heretofore made to Paragraphs through of Plaintiff's
Verified Complaint as if set forth in full herein.
11. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"66"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"66"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains
to the remaining defendants in the Verified Complaint.
12. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"67"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"67"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains
to the remaining defendants in the Verified Complaint.
13. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"68"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"68"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as itpertains
to the remaining defendants in the Verified Complaint.
14. Defêüdant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"69"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"69"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains
to the remaining defendants in the Verified Complaint.
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15. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"70" "70"
allegation contained in Paragraph (a) through (m) of Plaintiff's Verified Complaiñt,
insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form
"70" "70"
a belief as to the truth of each and every allegation contained in Paragraph (a) through (m)
of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified
Complaint.
16. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"71"
allegation emin;üed in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"71"
each and every allegation coñtaiñed in Paragraph of Plaintiff's Verified Complaint as it pertains
to the remaining defendants in the Verified Complaint.
17. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"72"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"72"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains
to the remaining defendants in the Verified Complaint.
18. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"73"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"73"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains
to the remaining defendants in the Verified Complaint.
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AS AND FOR AN ANSWER TO THE SECOND CAUSE OF ACTION
19. Defendant, ARMSTRONG INTERNATIONAL, INC. herein repeats, reiterates and
"1" "73"
re-alleges each and every answer heretofore made to Paragraphs through of Plaintiff's
Verified Complaint as if set forth in full herein.
20. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"75"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to fonn a belief as to the truth of
"75"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains
to the remaining defendants in the Verified Complaint.
21. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"76"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to fonn a belief as to the truth of
"76"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains
to the remaining defendants in the Verified Coroplaint.
22. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"77"
allegation contained in Paragraph of Plaintiff's Verified Complaint, and refers all questions of
law to this Court for determination at the time of trial, and Defendant, ARMSTRONG
INTERNATIONAL, INC. denies any knowledge or information sufficient to form a belief as to the
"77"
truth of each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it
pertains to the remaining defendants in the Verified Complaint.
23. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"78"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
(N0896399-l}
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"78"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains
to the remaining defendants in the Verified Complaint.
AS AND FOR AN ANSWER TO THE THIRD CAUSE OF ACTION
24. Defendant, ARMSTRONG INTERNATIONAL, INC. herein repeats, reiterates and
"1" "78"
re-alleges each and every answer heretofore made to Paragraphs through of Plaintiff's
Verified Complaint as if set forth in full herein.
25. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"80"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"80"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as itpertains
to the remaining defendants in the Verified Complaint.
26. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"81"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to fonn a belief as to the truth of
"81"
each and every allegation contained in Paragraph of Plaintiff's Verified Coniplaint as it pertains
to the remaining defendants in the Verified Complaint.
27. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"82"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"82"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains
to the remaining defendants in the Verified Complaint.
28. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"83"
allegation contained in Paragraph of Plaintiff's Verified Compkint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
(N0896399-1}
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"83"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains
to the remaining defendants in the Verified Complaint.
29. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"84"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"84"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains
to the remaining defendants in the Verified Complaint.
30. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"85"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"85"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains
to the remaining defendants in the Verified Complaint.
31. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"86"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"86"
each and every allegation coi1tailled in Paragraph of Plaintiff's Verified Complaiilt as it pertains
to the remaining defendants in the Verified Complaint.
32. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"87"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"87"
each and every allegation contained in Paragraph of Plaintiff's Verified Coi11plaint as it pertains
to the remaining defendants in the Verified Complaint.
33. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"88"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
(N0896399-1}
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this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"88"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as itpertaiñs
to the remaining defendants in the Verified Complaint.
AS AND FOR AN ANSWER TO THE FOURTH CAUSE OF ACTION
34. Defendant, ARMSTRONG INTERNATIONAL, INC. herein repeats, reiterates and
"1" "88"
re-alleges each and every answer heretofore made to Paragraphs through of Plaintiff's
Verified Complaint as if set forth in full herein.
35. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"90"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"90"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains
to the remaining defendants in the Verified Complaint.
36. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"91"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"91"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains
to the remaining defendants in the Verified Complaint.
37. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"92"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"92"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains
to the remaining defendants in the Verified Complaint.
38. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"93"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
(N0896399-1}
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this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"93"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains
to the remaining defendants in the Verified Complaint.
39. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"94"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"94"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as itpertains
to the remaining defendants in the Verified Complaint.
40. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"95"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"95"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as itpertains
to the remaining defendants in the Verified Complaint.
41. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"96"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"96"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains
to the remaining defendants in the Verified Complaint.
42. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"97"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"97"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as itpertains
to the remaining defendants in the Verified Complaint.
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43. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"98"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"98"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as itpertains
to the remaining defendants in the Verified Complaint.
44. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"99" "99"
allegation contained in Paragraphs (a) through (f) of Plaintiff's Verified Complaint, and
refers all questions of law to this Court for determination at the time of trial, and Defendant,
ARMSTRONG INTERNATIONAL, INC. denies any knowledge or information sufficient to form
"99" "99"
a belief as to the truth of each and every allegation contained in Paragraphs (a) through (f)
of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified
Complaint.
45. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"100"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"100"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it
pertains to the remaining defendants in the Verified Complaint.
46. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"101"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"101"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it
pertains to the remaining defendants in the Verified Complaint.
47. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"102"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
(N0896399-1)
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this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"102"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it
pertains to the remaining defendants in the Verified Complaint.
48. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"103"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"103"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it
pertains to the remaining defendants in the Verified Complaint.
49. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"104"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"104"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it
pertains to the remaining defendants in the Verified Complaint.
50. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"105"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"105"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it
pertains to the remaining defendants in the Verified Complaint.
51. Defendant, ARMSTRONG INTERNATIONAL, INC. denies any knowledge or
information sufficient to form a belief as to the truth of each and every allegation contained in
"106"
Paragraph of the Plaintiff's Verified Complaint.
52. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"107"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
(N0896399-1}
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"107"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it
pertains to the remaining defendants in the Verified Coiliplailit.
AS AND FOR AN ANSWER TO THE FIFTH CAUSE OF ACTION
53. Defendant, ARMSTRONG INTERNATIONAL, INC. herein repeats, reiterates and
"1" "107"
re-alleges each and every answer heretofore made to Paragraphs through of Plaintiff's
Verified Complaint as if set forth in full herein.
54. Defendant, ARMSTRONG INTERNATIONAL, INC. does not answer the
"109" "115"
allegations contained in Paragraphs through of Plaintiff's Verified Complaiiit as same
do not apply to this Defendant.
AS AND FOR AN ANSWER TO THE SIXTH CAUSE OF ACTION
55. Defendant, ARMSTRONG INTERNATIONAL, INC. herein repeats, reiterates and
"1" "115"
re-alleges each and every answer heretofore made to Paragraplis through of Plaintiff's
Verified Complaint as if set forth in full herein.
56. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"117"
allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to this
answering Defendant and Defendant, ARMSTRONG INTERNATIONAL, INC. denies any
knowledge or information sufficient to form a belief as to the truth of each and every allegation
"117"
contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining
Defendants in the Verified Complaint.
57. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"118"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"118"
each and allegation contained in Paragraph of Plaintiff's Verified Complaint as it
every
pertains to the remaining defendants in the Verified Complaint.
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58. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"119"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of
"119"
each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it
pertains to the remaining defendants in the Verified Complaint.
59. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every
"120"
allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to
this Defendant and denies any knowledge
Preview
FILED: NEW YORK COUNTY CLERK 08/05/2019 11:07 AM INDEX NO. 190153/2019 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 08/05/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK X PANTELIS KAMMAS and KLEO KAMMAS, Index No.: 190153/2019 Plaintiffs, - against - VERIFIED ANSWER A.O. SMITH WATER PRODUCTS, et al., Defendants, ___ X Defendant, ARMSTRONG INTERNATIONAL, INC., by its attorneys McGivney, Kluger & Cook, P.C. answering the Plaintiff's Verified Complaint upon information and belief, alleges as follows: THE PARTIES 1. Defendant, ARMSTRONG INTERNATIONAL, INC. denies any knowledge or "1" infonnation sufficient to form a belief as to the truth of the allegations in Paragraph of the Plaintiff's Verified Complaint. 2. Defendant, ARMSTRONG INTERNATIONAL, INC. denies any knowledge or "2" information sufficient to form a belief as the truth of the allegations of Paragraph and leaves Plaintiff to their proofs. 3. Defendant, ARMSTRONG INTERNATIONAL, INC. does not answer the "3" allegations of Paragraph of the Plaintiff's Verified Complaint as same do not apply to this Defendant. 4. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "4" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of {N0896399-l} 1 of 38 FILED: NEW YORK COUNTY CLERK 08/05/2019 11:07 AM INDEX NO. 190153/2019 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 08/05/2019 "4" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 5. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "5" allegation contained in Paragraph of Plaintiff s Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "5" each and every allegation contained in Paragraph of Plaintiff s Verified Coniplaint as it pertains to the remaining defendants in the Verified Complaint. 6. Defendant, ARMSTRONG INTERNATIONAL, INC. does not answer the "6" "8" allegations of Paragraphs through as it contains no allegations against the answering Defendant. 7. Defendant, ARMSTRONG INTERNATIONAL, INC. denies the allegations "9" contained in Paragraph of Plaintiff s Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of each "9" and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 8. Defendant, ARMSTRONG INTERNATIONAL, INC. does not answer the "10" "55" allegations of Paragraphs through as it contains no allegations against the answering Defendant. 9. Defendant, ARMSTRONG INTERNATIONAL, INC. denies the allegations "56" "64" contained in Paragraphs through of Plaintiff s Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth "56" "64" of each and every allegation contained in Paragraphs through of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. (N0896399-l} 2 of 38 FILED: NEW YORK COUNTY CLERK 08/05/2019 11:07 AM INDEX NO. 190153/2019 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 08/05/2019 AS AND FOR AN ANSWER TO THE FIRST CAUSE OF ACTION 10. Defendant, ARMSTRONG INTERNATIONAL, INC. herein repeats, reiterates and "1" "64" re-alleges each and every answer heretofore made to Paragraphs through of Plaintiff's Verified Complaint as if set forth in full herein. 11. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "66" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "66" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 12. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "67" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "67" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 13. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "68" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "68" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as itpertains to the remaining defendants in the Verified Complaint. 14. Defêüdant, ARMSTRONG INTERNATIONAL, INC. denies each and every "69" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "69" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. (N0896399-1) 3 of 38 FILED: NEW YORK COUNTY CLERK 08/05/2019 11:07 AM INDEX NO. 190153/2019 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 08/05/2019 15. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "70" "70" allegation contained in Paragraph (a) through (m) of Plaintiff's Verified Complaiñt, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form "70" "70" a belief as to the truth of each and every allegation contained in Paragraph (a) through (m) of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 16. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "71" allegation emin;üed in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "71" each and every allegation coñtaiñed in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 17. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "72" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "72" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 18. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "73" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "73" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. {N0896399-1 } 4 of 38 FILED: NEW YORK COUNTY CLERK 08/05/2019 11:07 AM INDEX NO. 190153/2019 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 08/05/2019 AS AND FOR AN ANSWER TO THE SECOND CAUSE OF ACTION 19. Defendant, ARMSTRONG INTERNATIONAL, INC. herein repeats, reiterates and "1" "73" re-alleges each and every answer heretofore made to Paragraphs through of Plaintiff's Verified Complaint as if set forth in full herein. 20. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "75" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to fonn a belief as to the truth of "75" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 21. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "76" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to fonn a belief as to the truth of "76" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Coroplaint. 22. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "77" allegation contained in Paragraph of Plaintiff's Verified Complaint, and refers all questions of law to this Court for determination at the time of trial, and Defendant, ARMSTRONG INTERNATIONAL, INC. denies any knowledge or information sufficient to form a belief as to the "77" truth of each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 23. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "78" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of (N0896399-l} 5 of 38 FILED: NEW YORK COUNTY CLERK 08/05/2019 11:07 AM INDEX NO. 190153/2019 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 08/05/2019 "78" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. AS AND FOR AN ANSWER TO THE THIRD CAUSE OF ACTION 24. Defendant, ARMSTRONG INTERNATIONAL, INC. herein repeats, reiterates and "1" "78" re-alleges each and every answer heretofore made to Paragraphs through of Plaintiff's Verified Complaint as if set forth in full herein. 25. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "80" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "80" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as itpertains to the remaining defendants in the Verified Complaint. 26. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "81" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to fonn a belief as to the truth of "81" each and every allegation contained in Paragraph of Plaintiff's Verified Coniplaint as it pertains to the remaining defendants in the Verified Complaint. 27. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "82" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "82" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 28. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "83" allegation contained in Paragraph of Plaintiff's Verified Compkint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of (N0896399-1} 6 of 38 FILED: NEW YORK COUNTY CLERK 08/05/2019 11:07 AM INDEX NO. 190153/2019 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 08/05/2019 "83" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 29. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "84" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "84" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 30. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "85" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "85" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 31. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "86" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "86" each and every allegation coi1tailled in Paragraph of Plaintiff's Verified Complaiilt as it pertains to the remaining defendants in the Verified Complaint. 32. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "87" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "87" each and every allegation contained in Paragraph of Plaintiff's Verified Coi11plaint as it pertains to the remaining defendants in the Verified Complaint. 33. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "88" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to (N0896399-1} 7 of 38 FILED: NEW YORK COUNTY CLERK 08/05/2019 11:07 AM INDEX NO. 190153/2019 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 08/05/2019 this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "88" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as itpertaiñs to the remaining defendants in the Verified Complaint. AS AND FOR AN ANSWER TO THE FOURTH CAUSE OF ACTION 34. Defendant, ARMSTRONG INTERNATIONAL, INC. herein repeats, reiterates and "1" "88" re-alleges each and every answer heretofore made to Paragraphs through of Plaintiff's Verified Complaint as if set forth in full herein. 35. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "90" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "90" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 36. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "91" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "91" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 37. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "92" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "92" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 38. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "93" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to (N0896399-1} 8 of 38 FILED: NEW YORK COUNTY CLERK 08/05/2019 11:07 AM INDEX NO. 190153/2019 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 08/05/2019 this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "93" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 39. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "94" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "94" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as itpertains to the remaining defendants in the Verified Complaint. 40. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "95" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "95" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as itpertains to the remaining defendants in the Verified Complaint. 41. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "96" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "96" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 42. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "97" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "97" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as itpertains to the remaining defendants in the Verified Complaint. (N0896399-1} 9 of 38 FILED: NEW YORK COUNTY CLERK 08/05/2019 11:07 AM INDEX NO. 190153/2019 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 08/05/2019 43. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "98" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "98" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as itpertains to the remaining defendants in the Verified Complaint. 44. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "99" "99" allegation contained in Paragraphs (a) through (f) of Plaintiff's Verified Complaint, and refers all questions of law to this Court for determination at the time of trial, and Defendant, ARMSTRONG INTERNATIONAL, INC. denies any knowledge or information sufficient to form "99" "99" a belief as to the truth of each and every allegation contained in Paragraphs (a) through (f) of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 45. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "100" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "100" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 46. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "101" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "101" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 47. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "102" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to (N0896399-1) 10 of 38 FILED: NEW YORK COUNTY CLERK 08/05/2019 11:07 AM INDEX NO. 190153/2019 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 08/05/2019 this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "102" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 48. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "103" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "103" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 49. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "104" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "104" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 50. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "105" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "105" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 51. Defendant, ARMSTRONG INTERNATIONAL, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in "106" Paragraph of the Plaintiff's Verified Complaint. 52. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "107" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of (N0896399-1} 11 of 38 FILED: NEW YORK COUNTY CLERK 08/05/2019 11:07 AM INDEX NO. 190153/2019 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 08/05/2019 "107" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Coiliplailit. AS AND FOR AN ANSWER TO THE FIFTH CAUSE OF ACTION 53. Defendant, ARMSTRONG INTERNATIONAL, INC. herein repeats, reiterates and "1" "107" re-alleges each and every answer heretofore made to Paragraphs through of Plaintiff's Verified Complaint as if set forth in full herein. 54. Defendant, ARMSTRONG INTERNATIONAL, INC. does not answer the "109" "115" allegations contained in Paragraphs through of Plaintiff's Verified Complaiiit as same do not apply to this Defendant. AS AND FOR AN ANSWER TO THE SIXTH CAUSE OF ACTION 55. Defendant, ARMSTRONG INTERNATIONAL, INC. herein repeats, reiterates and "1" "115" re-alleges each and every answer heretofore made to Paragraplis through of Plaintiff's Verified Complaint as if set forth in full herein. 56. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "117" allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to this answering Defendant and Defendant, ARMSTRONG INTERNATIONAL, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation "117" contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining Defendants in the Verified Complaint. 57. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "118" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "118" each and allegation contained in Paragraph of Plaintiff's Verified Complaint as it every pertains to the remaining defendants in the Verified Complaint. {N0896399-1} 12 of 38 FILED: NEW YORK COUNTY CLERK 08/05/2019 11:07 AM INDEX NO. 190153/2019 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 08/05/2019 58. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "119" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge or information sufficient to form a belief as to the truth of "119" each and every allegation contained in Paragraph of Plaintiff's Verified Complaint as it pertains to the remaining defendants in the Verified Complaint. 59. Defendant, ARMSTRONG INTERNATIONAL, INC. denies each and every "120" allegation contained in Paragraph of Plaintiff's Verified Complaint, insofar as they pertain to this Defendant and denies any knowledge